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Due Process: The Comment Letter

A vital part of the GASB’s mission statement requires the Board "to carefully weigh the views of its constituents so that standards and concepts will meet the accountability and decision-making needs of the users of governmental financial reports and gain general acceptance among state and local government preparers and auditors of financial reports…" Due process allows the Board to accomplish this goal through a variety of avenues—public hearings, public forums, task forces, and focus groups. However, the primary means by which the Board currently solicits feedback on its proposals is through a request for written comments.

Why should I or my organization write a comment letter?

When the GASB sets standards, a crucial part of the due process activities it engages in is the publication of proposals for public discussion and comment. Comment letters are the primary means by which interested individuals or groups can communicate with the Board on its proposals. The Board relies on the comments of those who prepare or audit financial statements for feedback on the conceptual soundness, technical accuracy, and appropriateness of its proposals. Additionally, comments from users are particularly helpful to the Board in understanding whether or not the information provided by the proposals is useful in fulfilling the needs of those who use governmental financial information.

Many constituents submit comments when they do not agree with the Board’s proposals. However, it is equally important to let the Board know when you support a proposal. One compelling comment can make a difference.

What should I include in my letter?

In order to help the Board reach its conclusions, it is important to keep in mind that the reasons for your position are even more important than the position itself. This is the case whether you agree with a proposal or you have concerns about the Board’s position. It is the argument supporting your position that will help the Board to understand the issues as you see them and to fully consider your point of view.

The substance of the comments received from each of the GASB’s constituents is more important than the total number of responses for or against any particular proposal. The Board’s request for comments is not an opinion poll, and the Board’s ultimate decisions are not necessarily those with the most popular support.

Should my letter address every issue raised in the due process document?

Not necessarily. Some due process documents cover many issues. In general, the more comprehensive your response, the more helpful it is to the Board. However, the Board also recognizes that each respondent has a different background and different experiences from which valuable feedback can be obtained, and that not all respondents will have comments on each issue addressed in the due process document. Therefore, respondents should focus on those issues that they are most interested in and are most knowledgeable about.

What happens to my letter once it is received by the GASB? Who reads my letter?

When a comment letter is received by the GASB, the letter becomes part of the public record. Copies of the letter are distributed to each Board member, as well as to all staff assigned to the project. The letter is scanned into an electronic format, and comments are analyzed, classified by issue, and entered into a database with all other responses received. Reports containing every comment by topic or issue are distributed to all Board members. Additionally, prior to the Board’s redeliberation of an issue, representative comments are incorporated into staff papers presenting the pros and cons raised during due process on specific subjects. This process ensures that every comment received is presented to the Board twice (and often three times) as issues are being deliberated.

When should I submit my comments?

When issuing a due process document, the Board establishes a comment deadline, which is identified on the front cover of the proposal. The length of time allowed for submission of comments varies depending upon the complexity and controversy of the proposals and the type of document issued. The Board comment period ranges from 30 to 120 days. Ninety days is the normal comment period.

How can I learn about new proposals?

The Board announces the issuance of each due process document in a press release and in its monthly newsletter, The GASB Report. Additionally, information about proposals is made available on the GASB’s web site (www.gasb.org).

All due process documents can be downloaded free from the GASB’s website, www.gasb.org. Members of the GASB’s subscription plan are notified immediately when due process documents become available.